Parish Council Publication Scheme: What to Include and How to Maintain It

A publication scheme is a document that tells the public exactly what information your council routinely publishes, where to find it, and on what terms. Every parish council must adopt the Information Commissioner's model publication scheme under Section 19 of the Freedom of Information Act 2000. It is a separate obligation from the Transparency Code, and the two are often confused.

This guide covers what the publication scheme must contain, how it differs from your Transparency Code obligations, and the maintenance routine that keeps it current at audit.

Publication scheme vs Transparency Code: the practical difference

The publication scheme comes from the FOI Act 2000. It applies to every public authority — including every parish council, regardless of turnover. It is a commitment to proactively publish certain classes of information so the public does not need to file a FOI request to see them.

The Transparency Code for Smaller Authorities applies only to councils with annual turnover under £25,000. It mandates specific items that must appear on the council's website (annual governance statement, internal audit report, draft minutes within a month, end-of-year accounts) and the format for them.

Both obligations sit alongside each other. The publication scheme is the higher-level document: the contents page that tells the public what you publish and where. The Transparency Code is a specific list of items the smaller-authority subset must publish in a particular way. A compliant council adopts both and links them together — the publication scheme references the Transparency Code disclosures as one of its information classes.

The seven classes of information

The ICO publishes a model publication scheme that all public authorities must adopt. The current scheme defines seven classes of information that every authority commits to publishing:

1. Who we are and what we do. Council structure, councillor names and contact details, clerk contact details, meeting frequency, ward boundaries, links to the principal authority.
2. What we spend and how we spend it. Approved budget, statement of accounts, internal audit report, external auditor's report, allowances and expenses, declarations of interest, financial regulations, list of payments above any threshold the council has set.
3. What our priorities are and how we are doing. Annual report, action plan, performance measures, projects underway.
4. How we make decisions. Agendas and minutes of council and committee meetings, reports presented to those meetings, background papers, decisions made under delegated authority.
5. Our policies and procedures. Standing orders, financial regulations, code of conduct, complaints procedure, grievance and disciplinary procedures, equality and diversity policy, data protection policy, IT policy, retention schedule.
6. Lists and registers. Register of members' interests, register of gifts and hospitality, asset register, list of suppliers.
7. The services we offer. Allotments, parks, halls, events, grants — anything the council provides directly.

For each class, the council states what is published, where it can be found, and any charging policy. For most parish councils the answer is "on our website, free of charge" — but you must still state it.

Building the scheme document

The ICO's Freedom of Information section publishes the model template. The job is not to write it from scratch — it is to populate it with your council's specifics.

Practical structure:

Section 1: Introduction. A short paragraph stating that the council adopts the ICO model publication scheme under section 19 of the FOI Act 2000.

Section 2: The seven classes. For each class, a short list of the documents the council publishes and where they are. Use direct links where possible — "see /minutes" not "see the minutes section of our website." This is a directly checkable signal at audit.

Section 3: How to access the information. State that information is available on the council website at no charge, and how members of the public can request information not currently published (the FOI request route, with the clerk as the named contact and the 20-working-day statutory response deadline).

Section 4: Charges. Most parish councils charge nothing. If the council intends to charge for hard copies, photocopying, or postage, the rates must be stated here. The ICO position is that charges should reflect actual costs only — not commercial rates.

Section 5: Date and review. The date the scheme was adopted, the date it was last reviewed, and the schedule for the next review (annually is standard).

What auditors actually check

Internal auditors checking the publication scheme look for four things:

• Adoption. A minute showing the council formally adopted the model scheme. If you can't show the minute, you have not adopted it.
• Currency. The scheme references documents that exist and links that work. A scheme listing "minutes for 2022" and nothing since is evidence the scheme has not been maintained.
• Coverage. All seven information classes are populated. Empty classes should say what is published, even if that is "the council does not currently publish a separate annual report — see the annual governance statement".
• Findability. The scheme is linked from the homepage or the main navigation. Burying it three clicks deep is a finding.

If the council is also subject to the Transparency Code (turnover under £25,000), the auditor cross-checks the items the Code requires against what the publication scheme says you publish. Mismatches are findings.

Common mistakes

Adopting the model and never reviewing it. A scheme adopted in 2018 and never refreshed is evidence the council is not actively maintaining it. The ICO expects annual review, and auditors will ask when it was last reviewed.

Linking to documents that no longer exist. Website rebuilds, document moves, and PDF archive cleanups break links. Walk every link in the scheme during the annual review. See our parish council website accessibility guide — broken document links also create accessibility failures because screen readers report them as 404s.

Conflating the scheme with the privacy notice. The publication scheme is about what you proactively publish. The privacy notice is about how you handle personal data. Both are required. They are not the same document.

Treating it as the only FOI route. The publication scheme covers what is routinely available. Members of the public retain the right to make FOI requests for information not in the scheme — the council must still respond within 20 working days. The scheme reduces the number of routine requests; it does not replace the FOI process.

Forgetting the asset register. Class 6 includes a list of assets. Many parish councils keep an asset register for AGAR (Assertion 6) but never publish it. The publication scheme commits you to making it available — review whether yours is on the website.

Where this connects to the rest of compliance

The publication scheme touches almost every other compliance area. It references the code of conduct (class 5), the financial regulations and audit reports (class 2), the transparency code disclosures (class 4), the privacy notice and IT policy (class 5), and the complaints procedure (class 5).

A useful annual maintenance routine: review the scheme at the same meeting where the council adopts the AGAR statement of accounts. The auditor is already preparing for the audit cycle, the policies are being refreshed for the new financial year, and the scheme can be brought current alongside everything else. Use the compliance checklist to track which sections of the scheme are up to date and which need attention before the next review.

Sources

• Freedom of Information Act 2000, Section 19 — publication schemes
• ICO — Freedom of Information for organisations (model publication scheme guidance and templates)
• GOV.UK — Transparency Code for Smaller Authorities
• Freedom of Information Act 2000 — full Act